Privacy
QTRLY is Making Tax Digital software for sole traders and landlords, currently in early access. This notice explains what personal data we handle across this website and the product, why we handle it, who helps us run the service, and the rights you have. As an early-access product, this notice may evolve as the product does; we will update this page and the date above when it changes. Some of the processing described below, including HMRC submissions and the sync history around them, begins only once direct filing to HMRC goes live; it is described here now so nothing changes without notice when it does.
Who we are
QTRLY is a product of Easy Insight Limited, a private limited company registered in England and Wales (Company No. 15217860). Registered office: 81 Milton Road, Portsmouth, Hampshire, PO3 6AL, United Kingdom. Easy Insight Limited is the controller for the personal data described in this notice. For anything here, email privacy@getmanifold.co.uk.
What we process
- Account data. Your name and email address, and your account settings.
- Tax data. Your National Insurance number, which identifies you to HMRC, the self-employment and property income and expense records you enter, and the history of submissions made to HMRC on your behalf.
- HMRC fraud prevention details. Every time you sync with HMRC or send a submission, HMRC requires the software making the call to attach a set of fraud prevention headers describing the device and connection it came from. So, on those calls only, we collect and pass on: your browser's user agent, the device identifier described under Cookies below, your screen width, height, scaling factor and colour depth, your browser window size, your timezone offset, your public IP address and the port it came from, and the internal identifier we use for your account. We collect these to put them in the HMRC headers and for nothing else. They are not used to profile you, to advertise to you, or to track you between visits.
- Billing metadata. Your plan and payment status. Card details are entered with Stripe, our payment provider, and never touch our servers.
- Technical data. Request logs and error reports, including IP addresses and browser information, used to keep the service secure and working.
- Early-access enquiries. If you contact us through this website, we collect your name, email address and any message you send, to get in touch with you.
Why we use it, and our lawful bases
- To provide the service (running your account, preparing and submitting your quarterly updates, billing): performance of a contract.
- To meet the conditions HMRC sets for filing software (the fraud prevention details above): performance of a contract, because we cannot make a submission you have asked for without them, and our legitimate interest, shared with HMRC and with you, in making it harder for someone else to file in your name. HMRC publishes these headers as a requirement for Making Tax Digital software and can refuse a submission that arrives without them.
- To keep the service secure (request logs, rate limiting, abuse prevention, error reporting): our legitimate interest in running a safe, reliable service.
- To meet legal obligations that apply to us, such as accounting and tax record-keeping.
- To respond to enquiries you send us: taking steps at your request before entering a contract, and our legitimate interest in talking to prospective customers.
Our sub-processors
These are the services we use to run QTRLY, and what each one does for you:
| Provider | What it does for QTRLY |
|---|---|
| Supabase | Database and authentication (your account and tax records). |
| Vercel | Hosting and serving of this website and the application, plus Vercel Analytics and Speed Insights, which count visits and measure page performance. Both are cookieless and neither builds a profile of you. |
| Stripe | Subscription billing. Card details are entered with Stripe and never touch our servers. |
| HMRC | The tax authority you file with once you connect your account to Making Tax Digital for Income Tax. Receives your National Insurance number, income and expense figures, and every submission made on your behalf. It also receives the fraud prevention details listed under “What we process” with every sync and every submission: your browser, device, screen and window details, your timezone, your public IP address and port, and our own identifier for your account. HMRC requires those details on every call and can refuse a submission sent without them. |
| Resend | Transactional email, such as deadline reminders. |
| Upstash | Rate limiting, to protect the service from abuse. Sees request identifiers such as IP addresses, not your records. |
| Sentry | Error and performance monitoring. Receives technical request and error details, not your records. |
Where your data goes
A few of these providers handle data outside the UK. Where that happens, we either rely on the UK government's own adequacy decision for that country, or put a contract in place first using a safeguard the UK has approved for this: the International Data Transfer Agreement or Addendum.
How long we keep things, and how deletion works
We keep your account and tax data for as long as your account is active, and for as long afterwards as we are required to for tax, accounting or legal reasons. Technical logs are kept for a limited period for security and troubleshooting, then deleted.
Asking us to delete your data. Email privacy@getmanifold.co.uk and ask. There is no delete button in the product: we handle these requests by hand, because filing records cannot be removed without checking first what tax law requires us to keep. We will complete the request within one month, which is the period UK data-protection law gives us. If it is complicated we may extend that by up to two further months, and if we do we will tell you inside the first month and explain why.
What we delete. Your account and sign-in details, your name and email address, any enquiry you sent us, the HMRC access and refresh tokens we hold for you, and any income or expense record you entered that has never formed part of a submission to HMRC.
What we keep, and why. Where a record forms part of a submission already made to HMRC on your behalf, we keep it for as long as tax law requires and then delete it. That covers your National Insurance number, the income and expense figures that went into a filed update, and the submission history itself, including the date, the period and what was sent. That history is the evidence of a legally binding filing, for you as much as for us, and UK data-protection law does not require us to erase personal data we are obliged to keep. We will always tell you what we deleted and what we kept.
How we protect it
Your account's data is isolated at the database with row-level security. Traffic is encrypted in transit (HTTPS). If you connect QTRLY to HMRC, your HMRC access and refresh tokens are encrypted at rest, in the same way as our other integration tokens. Your National Insurance number is protected by row-level security and by the database's encryption at rest, but is not separately encrypted at the application layer. More detail is on the security page.
Support access. Named Easy Insight Limited staff can open an account to investigate a problem or provide support. That access is time-limited, recorded in an append-only audit trail, and used only when support requires it, never for marketing or profiling.
Cookies, and what we store on your device
This site sets no analytics, advertising or profiling cookies. Signing in sets an essential cookie that keeps you signed in.
The device identifier. The product also stores one item in your browser's local storage, under the name manifold-hmrc-device-id. It is a randomly generated identifier, created the first time you sync with HMRC or send a submission, and it is meant to stay on your device so that the same device reports the same identifier on every later call. HMRC requires that in the fraud prevention headers described above, which is why it is set without asking you: it is strictly necessary to deliver the filing you asked for, and UK rules on storing data on your device do not require consent for that. It holds nothing about you: it is a random value, not derived from your name, your account or your hardware. Clearing your browser storage removes it, and a new one is created next time. If your browser blocks storage altogether, we generate a one-off value for that call and store nothing.
We do measure visits and page performance, using Vercel Analytics and Speed Insights. Both are cookieless: they store nothing on your device and neither builds a profile of you. Nothing else is stored on your device, and nothing here asks for your consent because nothing here needs it. If we ever add something that does, we will update this notice and ask first.
Your privacy rights
Under UK data-protection law you can ask us for a copy of the personal data we hold about you, ask us to correct it, delete it (subject to the retention above), restrict or object to how we use it, or ask for it in a portable format. Email privacy@getmanifold.co.uk and we will respond within a month.
Withdrawing your HMRC authority. The authority you give us to act on your HMRC account is yours to take back. Asking us to disconnect deletes the HMRC access and refresh tokens we hold and marks the connection as disconnected, so nothing further can be sent to HMRC on your behalf. It does not delete your records or your submission history: withdrawing authority and deleting data are different requests, and the section above covers the second. Two things to know. It takes effect at our end only, so please also remove QTRLY from the authorised software in your own HMRC online account. And it is not the same as closing your account, which you can do under the terms. To disconnect, email privacy@getmanifold.co.uk.
You also have the right to complain to the Information Commissioner's Office at ico.org.uk. We would appreciate the chance to help first, but you can go to them at any time.